This modern slavery and human trafficking statement (the “Statement”) is published on behalf of Communify Group Holdings, LP (d/b/a Communify), and its subsidiaries to describe the steps Communify has taken during the financial year ended December 31, 2025 to identify, assess, prevent, mitigate, and respond to risks of modern slavery, forced labor, child labor, and human trafficking in its operations and supply chains. This Statement is intended to support reporting under applicable modern slavery and supply chain transparency laws, including, where applicable, the United Kingdom’s Modern Slavery Act 2015, Australia’s Modern Slavery Act 2018 (Cth), and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (referred to herein collectively as the “Modern Slavery Acts”).
Communify assesses annually whether specific reporting obligations apply in each jurisdiction based on its business activities, corporate structure, revenue, operations, and supply chain.
Communify uniquely unifies the digital communication of market and client data to provide intelligent insights for investors and investment professionals through the Communify Digital Knowledge Base. Founded on decades of maturity in delivering complex market data at scale to some of the largest firms in financial services, Communify’s SaaS platform and Knowledge Base allow excellent experiences in consuming and visualizing complex information through a library of financial apps, including AI Apps (MIND-AI™). Communify’s Digital Knowledge Base of 4000+ unique data feeds informed by 500M+ user driven page views per day also powers Communify’s advanced AI capabilities for the next generation of communication, automation, and management of financial data.
Our Commitment
Communify is committed to maintaining the highest standards of ethical conduct and firmly opposes all forms of modern slavery, including forced labor, debt bondage, child labor, and human trafficking. As a global company, Communify recognizes our responsibility to the communities in which we operate and have embedded our broader corporate social responsibilities within our Code of Business Ethics.
Communify prohibits the use of any form of slave, forced, bonded, indentured, or involuntary labor and expects our employees, vendors, contractors, data providers, and other business partners to conduct business in a legal, ethical, and responsible manner.
Our Operations and Supply Chains
Communify is a Financial AI, Digital, Data, and SaaS solutions business serving financial services, online brokerage, wealth management, asset management, and media and information clients. Our supply chains primarily include cloud infrastructure, software and technology providers, market and reference data providers, professional services, recruiting and staffing support, facilities, travel, marketing, office equipment, and other corporate services.
Communify’s modern slavery risk profile is generally associated with third-party supply chains and supporting corporate services rather than the direct provision of its SaaS and data solutions. Communify continues to develop its understanding of its supply chain and to focus its review on categories where risks may be more salient
Policies and Governance
Communify’s Code of Business Ethics sets expectations for integrity, legal compliance, confidentiality, privacy, anti-bribery, conflicts of interest, responsible business practices, global human rights, modern slavery, reporting concerns, and non-retaliation. All our associates receive annual Code of Business Ethics training and are required to acknowledge the Code.
Communify expects vendors to comply with applicable modern slavery, forced labor, child labor, human trafficking, employment, anti-bribery, data protection, and human rights laws and with applicable contractual standards. Communify may decline, suspend, or terminate relationships with vendors that present unacceptable risk, fail to cooperate with due diligence, or fail to implement appropriate corrective action. Where concerns are identified, Communify will consider appropriate remediation and responsible disengagement based on the circumstances.
Risk Assessment
Communify uses a risk-based supplier review process that considers supplier location, industry, services provided, workforce profile, subcontracting, adverse media, contractual commitments, available information regarding prior allegations or findings, and the nature and criticality of the supplier relationship.
Communify prioritizes enhanced review for suppliers in higher-risk geographies, labour-intensive services, hardware or equipment supply chains, recruitment and staffing, facilities services, and other categories where modern slavery risks may be more salient.
Due Diligence and Remediation
Communify reviews new suppliers and identifies potential risks within its supply chain. Communify also conducts ongoing reviews of existing vendors to monitor potential risks related to modern slavery.
Due diligence measures may include supplier questionnaires, adverse media review, sanctions and watchlist screening where appropriate, review of supplier policies, contractual commitments, escalation to Legal, Compliance, Procurement, or senior management, and corrective action tracking.
Communify maintains reporting channels for employees and other stakeholders to raise concerns and prohibits retaliation for good-faith reports. Where Communify identifies actual or suspected modern slavery risk, it will evaluate appropriate remediation, which may include investigation, supplier corrective action, worker protection measures, cooperation with authorities or expert organizations where appropriate, and responsible termination where remediation is not feasible.
Training
All our associates receive annual Code of Business Ethics training and are required to provide an acknowledgement of acceptance of our Code of Business Ethics.
Communify addresses modern slavery, forced labor, child labor, human trafficking, and human rights expectations through its Code of Business Ethics, annual Code acknowledgement process, and policy communications. Communify intends to evaluate additional role-based guidance for employees involved in procurement, vendor onboarding, contracting, compliance, human resources, and vendor management.
Assessing Effectiveness
Communify assesses the effectiveness of its approach through measures such as completion of Code of Business Ethics training, use of supplier due diligence and onboarding controls, escalation and resolution of reported concerns, periodic review of higher-risk vendors, inclusion of modern slavery or human rights commitments in relevant agreements, and annual review of this Statement and related policies.
Communify expects to continue improving its supplier standards, risk assessment process, and reporting metrics.
Approval
This Statement has been prepared in consultation with relevant firmwide functions and approved by the Board of Managers of Communify Group Holdings, LP on June 25, 2026.
